HomeMy WebLinkAbout20250989 Rt 9 / South Broadway Special Use Permit Public CommentSustainable Educate.
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April 27, 2026
Re: Planning Board Application #20250989 — Rt 9 / South Broadway Special Use
Permit
Dear Chairman Pingle and members of the Planning Board,
Thank you for reviewing Sustainable Saratoga's comments regarding the
referenced mixed -use development application in the South Broadway Gateway
Commercial —Rural (GC-R) zoning district. While the applicant may demonstrate
compliance with applicable dimensional and use standards in the Unified Development
Ordinance (UDO), such compliance addresses only certain regulatory requirements.
The Board must also consider whether the project is consistent with the character and
intent that the community, through the Comprehensive Plan, has established for this
corridor -- a key rural gateway to the city. We are concerned that approval of this project
would set a precedent for incremental erosion of that vision, leading over time to
large-scale urban or suburban forms of development in areas intended to retain "rural
character." This is precisely the outcome the Comprehensive Plan's gateway
designation seeks to prevent.
Rural Gateways: What the City's Plans Call For
Both the City's 2015 Comprehensive Plan and the UDO are clear about the
purpose of the GC-R district. The city's Comprehensive Plan describes gateways as
permitting uses "that focus on maintaining a distinct entrance to the City," and that the
"goal for the commercial gateways is not to foster more intense or dense land use
development" but rather to focus on physical appearance and attractiveness. In turn, the
UDO states that the GC-R District is: "intended to accommodate commercial
development of a suitably rural, low -intensity character, creating a gateway at the
edge of the City and into key character areas that celebrates and preserves the natural
beauty and rural character."
Furthermore, the City's Natural Resources Inventory and Open Space Plan,
policy documents passed unanimously by recent City Councils, reinforce the
Comprehensive Plan's rural gateway vision by emphasizing protection of natural
landscapes, ecological connectivity, and low -intensity land use patterns in these areas.
The language in all of these city documents is deliberate and consistent. The
GC-R district is meant to serve as a visual and ecological complement to the open
landscapes to the south and a contrast to the more compact urban character closer to
downtown.
ar Board of Directors: Jeff Altamari (Treasurer), Jeff Buxbaum, Amy Durland (Chair), Carla Fox, Bethany Khan
(Vice Chair), Judi Knispel, Dianna Goodwin, Sarah Goodwin, Harry Moran, Paul Murphy, Beth Plummer
(Secretary), Bob Radliff, David Sayer, David Washburn
Sustainable Saratoga l PO Box 454, Saratoga Springs, NY 12866 1 www.sustainablesaratog i.or I info@sustainablesaratoga.org
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Dimensional Compliance Is Not Enough
Zoning standards are tools for implementing the broader land -use intent
expressed in the Comprehensive Plan. A building that fits within setback, height, and
density limits may still fail to embody the rural gateway character expressed in the
Comprehensive Plan and codified in the UDO's "district purpose." The test is
not whether a proposal can "fit" but whether it actually belongs. When one asks, "Does
this project look and feel like a rural gateway into a historic city?" an honest answer is
that it does not.
The Planning Board has both the legal authority and the responsibility to interpret
compliance in light of character and intent, not just dimensional conformity.
What "Rural Character" Means
In the GC-R district, "rural character" is defined by the preservation of natural
landforms, continuity of ecological systems, and development that is limited in intensity
and subordinate to the landscape. This is reflected in:
• Development patterns that complement the landscape, with small-scale clustered
buildings and generous open -space buffers.
• Landscaping that relies on existing tree -lines and landforms, native vegetation,
and minimal grading.
• Building scale and massing appropriate to a rural gateway, avoiding the
appearance of a large suburban complex.
A sense of arrival that signals entry into a community that values natural beauty
and thoughtful design.
Concerns Expressed by NYSDOT
A letter submitted by New York State Department of Transportation (NYSDOT)
raises several significant planning issues. While DOT normally focuses on traffic and
safety, the letter explicitly notes that the proposed development appears inconsistent
with the City's Comprehensive Plan and other planning documents. Specifically, the
letter expressed concern that:
The proposed design introduces excessive impervious surface and vehicular
activity inconsistent with the Plan's call for green gateway corridors that protect
visual quality and reduce stormwater impacts;
The project's layout undermines environmental goals articulated in the
Comprehensive Plan by increasing runoff and fragmenting existing open
landscapes; and
The proposed commercial mix could compete with the city's compact,
walkable downtown, contrary to the Comprehensive Plan's growth management
goal of concentrating higher -intensity commercial activity in the urban core.
,or Board of Directors: Jeff Altamari (Treasurer), Jeff Buxbaum, Amy Durland (Chair), Carla Fox, Bethany Khan
(Vice Chair), Judi Knispel, Dianna Goodwin, Sarah Goodwin, Harry Moran, Paul Murphy, Beth Plummer
(Secretary), Bob Radliff, David Sayer, David Washburn
Sustainable Saratoga I PO Box 454, Saratoga Springs, NY 12866 1 www.sustainablesaratopa.ore I info@sustainablesaratoga.org
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These comments are particularly notable because they extend beyond typical traffic
engineering review. This underscores how the current proposal conflicts not only with
aesthetic intent but with the city's overarching environmental and economic
development blueprint.
The Precedent Problem
Approving a project of this scale and intensity in the GC-R district would establish
a precedent that would be increasingly difficult to reverse. In the GC-R area further
south on Route 9, applicants will cite this approval to justify similar large-scale
suburban -style designs, gradually eroding the city's carefully planned gateway
character. Over time, the corridor will lose its identity as a rural feature of the Greenbelt
and instead take on the appearance of a generic residential/commercial strip,
weakening both visitors' sense of arrival and the city's long-established planning vision.
An important observation about the UDO
This application highlights a broader structural problem for the city. The city's
zoning regulations embodied in the LIDO are required to align with the Comprehensive
Plan under New York State law. As this application demonstrates, the UDO's
dimensional and use standards, in practice, allow forms of development that are difficult
to reconcile with the Comprehensive Plan's stated objective of preserving rural gateway
character. Where such tension exists, the zoning framework needs to be amended to
comply with the Comprehensive Plan, the primary expression of the community's intent.
The UDO's consistency with the Comprehensive Plan is not optional. It is essential
to maintaining the integrity of the City's long-term planning framework and to ensuring
the city's compliance with state law.
Put another way, the Comp Plan's rural gateway concept is fundamentally driven
by design and "rural character" — low- to moderate -intensity uses, emphasizing
aesthetics and open space, creating a clear visual cue that you are entering "the City in
the Country." The UDO's purpose clause for this gateway echoes that language, but the
actual use, dimension, and design tables permit commercial and residential buildout
inconsistent with the "rural gateway" intent of the Comprehensive Plan. This proposal
exposes a misalignment between the Comprehensive Plan's clear direction and the
dimensional allowances of the UDO.
Recommendations to the Planning Board
1. Require clear demonstration that the proposal meets the intent of the GC-R
district's rural character, not merely dimensional compliance.
Board of Directors: Jeff Altamari (Treasurer), Jeff Buxbaum, Amy Durland (Chair), Carla Fox, Bethany Khan
(Vice Chair), Judi Knispel, Dianna Goodwin, Sarah Goodwin, Harry Moran, Paul Murphy, Beth Plummer
(Secretary), Bob Radliff, David Sayer, David Washburn
Sustainable Saratoga I PO Box 454, Saratoga Springs, NY 12866 1 wwwsustainablesaratoga.orI info@sustainablesaratoga.org
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2. Apply Comprehensive Plan consistency as a substantive review criterion,
giving particular weight to policies on gateway design, environmental
stewardship, and protecting the city's core as the growth engine, rather than
succumbing to sprawl.
3. Incorporate the guidance of the NRI and Open Space Plan as city reference
documents when assessing design appropriateness and landscape treatment.
4. Encourage redesign and/or reduced intensity of uses that contribute to traffic
intensity, impervious coverage, or visual clutter inconsistent with a rural gateway.
5. Adopt a clear interpretive statement or resolution reaffirming that "rural
gateway" zoning standards will be applied in full alignment with the
Comprehensive Plan's intent —thereby discouraging precedent for the
suburbanization of this rural corridor.
South Broadway is one of the first views that visitors and residents encounter when
entering Saratoga Springs from the south. Sustainable Saratoga urges the Planning
Board to uphold the full intent of the city's adopted plans in its review of this important
rural gateway.
Respectfully,
Kelsey Trudell, Executive Director
Cc: Design Review Board
Amy Durland, Chair of the Board
I Board of Directors: Jeff Altamari (Treasurer), Jeff Buxbaum, Amy Durland (Chair), Carla Fox, Bethany Khan
(Vice Chair), Judi Knispel, Dianna Goodwin, Sarah Goodwin, Harry Moran, Paul Murphy, Beth Plummer
(Secretary), Bob Radliff, David Sayer, David Washburn
Sustainable Saratoga I PO Box 454, Saratoga Springs, NY 12866 1 www.sustainablesaratoga.oi'Q I info@sustainablesaratoga.org